Doubling of limits, simplified administration, and preferential taxation available to a much broader range of businesses.
One of the key messages of the 2025 autumn tax package for the domestic SME sector is clear: from 2026, the KIVA (Small Business Tax) will become significantly more attractive, as the main entry and exit thresholds are set to double. Until now, the small business tax was particularly advantageous for smaller, labor-intensive companies, but after the changes, an increasing number of businesses with higher revenues can realistically consider it as well.
Regisztráljon és nézze vissza a webinár felvételét!
Under the amendment, for entry into the KIVA system, the revenue and balance sheet thresholds will increase from HUF 3 billion to HUF 6 billion, while the headcount limit will rise from 50 to 100 employees. Equally significant is the change regarding the termination of KIVA status: the revenue threshold will increase from HUF 6 billion to HUF 12 billion, and the headcount limit will extend up to 200 employees. The Hungarian Tax Authority (NAV) will already apply these higher limits to taxpayers who opt for KIVA on or after 1 December 2025. This means that KIVA, which is already a favorable and simple alternative to the combination of corporate tax and social contribution, will become a viable option for hundreds of thousands of additional businesses.
The logic of the small business tax remains unchanged: KIVA, at a 10% rate, replaces the corporate tax (9%) and the social contribution tax (13%). However, this 10% is not applied to the conventional corporate tax base, but to a special tax base primarily derived from personnel-related expenditures, which is adjusted by various increasing and decreasing items. The advantage of the system is that companies pay significantly lower taxes on wage costs—which are the largest expense for most service providers—while profits can be effectively deferred until dividend approval.
Not sure whether switching to KIVA from 2026 would benefit your company?
To qualify for KIVA, several conditions must still be met. The most important include that the company’s previous-year revenue and balance sheet total (including affiliated companies) must not exceed HUF 6 billion, the average statistical headcount may not exceed 100 employees, and the company must not have had its tax number legally cancelled in the past two years. KIVA can still be elected mid-year, with tax liability taking effect on the first day of the month following the declaration. However, starting in January remains the most practical, as this avoids a partial fiscal year and significantly simplifies the related administration.
Regarding the calculation of the tax base, the starting point remains personnel-related expenditures, which are increased by items such as capital withdrawals, dividend approvals, growth of cash balances, or expenses unrelated to the business purpose. Conversely, capital injections, received dividends, and decreases in cash balances reduce the tax base.
From 2026, an important clarification is introduced: the law explicitly separates cash from electronic funds, meaning the latter no longer needs to be treated as cash when applying the exempt cash balance rule.
KIVA does not only replace corporate tax and social contributions but also simplifies the calculation of the local business tax (HIPA). At year-end, a company can choose to determine the HIPA base as 1.2 times the KIVA base. This is particularly advantageous for companies where the local tax base calculation would otherwise be complex, potentially risky due to deductible items, or where there are few deductible items by nature of their operations. For these companies, the simplified method often results in a lower tax burden.
Profit taxation for KIVA companies follows a unique approach. Profits generated during the KIVA period do not incur a separate “profit tax” until dividends are approved above the retained earnings carried over from the corporate tax period. When dividends are approved, the amount is added as an increasing item and taxed at the current KIVA rate.
With the higher thresholds, the number of companies for which switching to KIVA is worthwhile expands significantly. It can be particularly advantageous for labor-intensive service companies (such as IT, consulting, operations, and agencies), growth-phase companies reinvesting profits, and those that were previously simply too large under the old HUF 3 billion thresholds.
Overall, the 2026 changes position KIVA as one of the most competitive tax options for the SME sector. It remains simple, wage-based, and flexible, while now opening the door for much larger businesses. In many cases, the question is no longer whether it is worth switching to KIVA, but when and under which structure the greatest benefit can be realized.
Author: Tamás Mendöl, Senior Tax Advisor, ICT Business Advisory Zrt.
Request a consultation and our experts will help you find the tax solutions that best fit your business.
Regisztráljon a webináriumra és legyen naprakész a vállalati adóoptimalizálással kapcsolatban!
Jogi nyilatkozat:
Jelen írás tájékoztató jellegű, nem minősül tanácsadásnak. Konkrét döntés előtt kérje szakértőnk személyre szabott véleményét.
